Comments

5 thoughts on “Top Priority: Undoing Dodd-Frank”

Eliminate foreclosure and shortsales from comps. Or if they are to be included in comps have them be noted as shortsale or foreclosure transactions so the US can begin to regain the $40 trillion dollar loss in equity.?

Do not require mortgage brokers to count fees such as title insurance, mortgage insurance premiums, appraisal, discount fees (non-income producing items) in the 3% points and fees cap, unless that broker has an affiliation with the party providing those services. Currently this makes a completely unlevel playing field between banks and brokers and lessens active competition in the market for consumers. It even prevents a consumer from obtaining a single pay mortgage insurance premium in some cases.

OK, if we are going to have a 3 day right of rescission upfront on the CD, get rid of it on the back end. Plus, who said 3 days is some kind of magical number? Aaaaand, why don’t all days count? People don’t read CDs over the weekend or something? If your CD expires on a Saturday or Sunday, you have until Monday. I would propose a 24 hour of having your CD before you can sign but get rid of the 3 days after. Glad to hear that these guys are at least considering common sense solutions, let’s get some loans done!!!

APPRAISERS!! Gut AMC’s. From the largest lending institutions AMC’s were born. How is this beneficial to the process, how is it “independent”, how is it saving the homeowner’s money? It isn’t. The AMC’s dictate which appraiser is to be used and the fee to be paid. This has caused an enormous shift in appraiser independence and fee reimbursement. Under Dodd-Frank fees (paid to the appraiser) have gone down about 40% from what is reasonable and customary. While “appraisal fees” charged to the homeowner have increased. This has primarily been due to AMC’s taking a major portion of the appraisal fee. A new approach which would provide better Consumer Protection would be to separate the fees on the HUD-1 statement. The Consumer would see exactly what they’re being charged: Reasonable Fees to the Appraiser for Valuation Services, plus a “Management Fee” for the A M C. The A M C “service” is actually provided to the lender. The Appraiser should not be paying for it with reduced fees.

revise the ATR rule (Ability to Repay)such that self-employed people with equity (LTV 75% or less), lots of $$ in the bank, and excellent credit (>=740), can qualify for loans even if their tax returns don’t show enough income because they write everything off. What’s riskier – an FHA or CONV 3% loan with 640 credit scores and very little money in the bank, or a CONV 75% LTV loan, 500k in the bank, and 740+ credit scores? This rule has absolutely crushed otherwise qualified self-employed business owners.